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LEGAL & PRIVACY

Terms and Conditions

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In consideration of International Assets Advisory, LLC ("IAA"), Blacor USA ("USA") or Blacor Investments ("Blacor") permitting you access to certain information, documents and other materials through BlacorUSA and Blacor Investments World Wide Web site on the internet (www.iaac.com)(www.blacorusa.com)(www.blacorpusa.com), you (which term, as used herein, includes you personally and the company or other organization on whose behalf we grant you access to the Site) hereby agree to the following terms and conditions (this "Agreement"). This Agreement is in addition to, and does not nullify, any other agreement ("Customer Agreement") between you, IAA, Blacor, or BlacorUSA governing the conduct of your relationship with "IAA," "Blacor" or "USA."

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You acknowledge that the Site is for informational purposes only and does not constitute investment advice, an offer to sell, or a solicitation of an offer to buy any security, other investments or investment services, which may be referred to in the Site. You also acknowledge that not all securities, other investments or investment strategies are suitable for or are eligible to be offered to all investors. If you interested or have any questions about any security, other investment, investment strategy or investment service discussed in the Site, we urge you contact your IAA Account Representative.

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Access Provided

Your access to the Site and/or the Material may be modified by IAA/Blacor/USA at any time or from time to time with or without notice. You agree to comply with any rules or restrictions posted by Blacor/USA on the Site.

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No Obligation to Keep Information Current

The Material reflects the respective authors' analyses as of the date each such Material was initially published. Further, Blacor/USA is not under any obligation to update the Material to reflect circumstances that may occur after the date initially published. Due to legal restriction or other reasons, IAA/Blacor/USA may not update any Material to take into account material changes or new information.

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Blue Sky and Foreign Laws

The Material may discuss numerous securities, some of which may not be qualified for sale in certain states or countries, and therefore, may not be offered to investors in such states or countries. Furthermore, Investing in securities denominated in currencies other than the U.S. dollar involves certain considerations comprising both risk and opportunity not typically associated with investing in U.S. securities. The security may be affected either favorably or unfavorably by fluctuation in the relative rates of exchange between the currencies, by exchange control regulations, or by indigenous economic and political developments.

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Disclaimers

The information contained in this Site is based on carefully selected sources, believed to be reliable, but whose accuracy or completeness cannot be guaranteed. Any opinion herein reflects our judgment at this date and is subject to change without notice. Affiliates, officers, directors, and employees of IAA/Blacor/USA, may be long or short and buy or sell securities mentioned in this Site. This publication is not and should not be construed as an offer or solicitation to buy or sell securities mentioned herein.

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SEC-Required report on routing of customer orders

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SEC Rule 606: Order Routing Practices

Blacor/USA through International Assets Advisory LLC is required to make available quarterly reports that present a general overview of our routing practices. These reports identify the significant venues to which customer orders were routed for execution during the applicable quarter.

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Blacor/USA through International Assets Advisory, LLC transmits the majority of our customer orders to our clearing firm, Royal Bank of Canada (RBC), Member NYSE/SIPC. RBC may then route these orders to various venues for execution. Customers of IAA/Blacor/USA may also request a written copy of this report. To obtain information about the routing of a specific order executed within the prior six months, please send your written request to International Assets Advisory, LLC, 390 North Orange Avenue, Suite 750, Orlando, FL 32801 or to view the SEC Rule 606 Report for the most recent quarter, click below:

SEC Rule 606 Qtr Ending September 30, 2018

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To view our policy regarding Trade Execution Quality, click the following

Trade Execution Quality

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Blacor/USA anti-money laundering compliance is monitored through INTERNATIONAL ASSETS ADVISORY, LLC

Anti-money laundering program

In response to the terrorist attacks on September 11, 2001 , the US Congress passed the USA Patriot Act (Patriot Act). Section 326 of the Patriot Act provides that Treasury and SEC issue a rule that, at a minimum, requires broker/dealers to implement reasonable procedures to: (1) verify the identity of any person seeking to open an account, to the extent reasonable and practicable; (2) maintain records of the information used to verify the person's identity; and (3) determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to brokers or dealers by any government agency.

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For more information on the USA Patriot Act please visit the FINRA website at www.finra.org

International investing or emerging markets

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International investing involves additional risks such as currency fluctuations, differing financial and accounting standards, and possible political and economic instability. Also, investing in emerging markets can be riskier than investing in well-established foreign markets. There is no assurance any of the trends mentioned will continue in the future. Investing involves risk and investors may incur a profit or a loss, including the loss of all principal.

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Asset Allocation Disclosure

Asset allocation does not ensure a profit or protect against a loss. Investing involves risk and investors may incur a profit or a loss. There is an inverse relationship between interest rate movements and fixed income prices. Generally, when interest rates rise, fixed income prices fall and when interest rates fall, fixed income prices rise. International investing involves special risks, including currency fluctuations, different financial accounting standards, and possible political and economic volatility. Declines in the value of real estate, economic conditions, property taxes, tax laws and interest rates all present potential risks to real estate investments. Alternative investments involve specific risks that may be greater than those associated with traditional investments and may be offered only to clients who meet specific suitability requirements, including minimum-net-worth tests. This information is not a complete summary or statement of all available data necessary for making an investment decision. Investing involves risk and investors may incur a profit or a loss. You should discuss any tax matters with the appropriate professional.

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Tax/Professional Advice Disclosure

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While we are familiar with tax matters, as affiliates of IAA/Blacor/USA are not qualified to render advice on tax or legal matters. Clients are advised to consult the appropriate professional for advice.

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Historical or past performance

Past performance is not a guarantee of future results. Past performance may not be indicative of future results.

 

Risk Disclosure

The investment return and principal value of an investment security will fluctuate with market conditions so that when redeemed the value of the investment may be worth more or less than the original cost.

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Business continuity planning disclosure statement

International Assets has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us - If after a significant business disruption you cannot contact us as you usually do at 407-254-1500 or 800-432-0000, you should call our clearing firm, Royal Bank of Canada (RBC) for instructions on how it may provide prompt access to funds and securities, enter orders and process other trade-related, cash, and security transfer transactions.

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Our Business Continuity Plan - We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm's books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

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Our business continuity plan addresses: data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

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Our clearing firm, Royal Bank of Canada (RBC), backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within 24 to 48 hours or sooner. Your orders and requests for funds and securities could be delayed during this period.

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Varying Disruptions - Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within one trading day. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within a very short reasonable time. In either situation we plan to continue business and notify you through our website www.iaac.com how to contact us.

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For more information - If you have questions about our business continuity planning, you can contact us at 407-254-1500 or 800-432-0000 or contact your financial advisor.

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Business Continuity In The Event Of A Business Disruption

Royal Bank of Canada (RBC) has an extensive and sophisticated business continuity plan in place to safeguard your assets and protect vital account information.

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To view the Royal Bank of Canada's (RBC) business continuity statement, please visit https://www.rbcwealthmanagement.com/us/en/legal/business-continuity-plan Royal Bank of Canada (RBC) and our broker dealer are proud of their respective privacy and confidentiality practices. As the custodian and clearing firm for your brokerage account, Royal Bank of Canada (RBC) has crafted a privacy policy that describes its practices pertaining to the collection, use, disclosure, and safeguarding of your personal information.

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Privacy Policy

The following describes how International Assets Advisory, LLC ("IAA"), Blacor USA ("USA") and Blacor Investments (Blacor) handles your personal information and what steps we take to protect your privacy:

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IAA/Blacor/USA has access to customer information for legitimate business purposes only. Only those employees who provide products or services to you or those who need your information to service your account are authorized to access your information. The company requires its employees who have access to customer information to protect it and keep it confidential.To conduct regular business, we may collect nonpublic personal information from sources such as, information reported by you on applications or other forms you provide to us, information you report directly to your registered representative, and information about your transactions with our affiliates or others.

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Security Standards

We safeguard this information in accordance with federal standards and established security standards and procedures. Measures we take in this regard include implementation of physical, electronic and procedural safeguards.

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Company Mailing Choice

Unless we receive your objection, International Assets Advisory LLC may be required under the provisions of rule 14b-1 of the of the U.S. Securities and Exchange Act of 1934, as applicable, to release your name, address and number of shares to the issuers of securities you hold through International Assets Advisory LLC. If you object, you will not receive any corporate communications mailed out by the issuer other than regulatory mailings required to be sent out to all holders, which you will receive from us. If you wish to exercise this preference, please contact us.

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Contact Us

To change your privacy preferences, provide us with updated information, report suspected fraud or identity theft, or for any other questions, please contact us.

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